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LAW OFFICE OF TODD J. KROUNER, P.C.
93 NORTH GREELEY AVENUE
CHAPPAQUA, NEW YORK 10514
(914)238-5800
TODD J. KROUNER*
*ADMITTED IN NY AND NJ
May 28, 2019
VIA ECF
Hon. Joan. B. Letkowitz, JSC
Attn: Jeannette Millner, Esq.
Court Attorney Referee
Westchester County Courthouse
111 Dr. Martin Luther King, Jr.,Boulevard, Courtroom: 800
White Plains, New York 10601
Re: Buckstine v. Schor. et al.
Index No.: 57710/2016
Dear Judge Lefkowitz:
I am the attorney for the plaintiff in the above-referenced action. Enclosed is a fully
executed Trial Readiness Stipulation and Order ("Stipulation") for Your Honor's review and
signature.
Based on this Stipulation, counsel for the parties are not appearing at tomorrow's Trial
Readiness Conference.
Respectfully submitted,
Todd J. er
TJK/ag
cc: Frank Malpigli, Esq.
Kimberly Hunt Lee, Esq.
Stephen Donohue, Esq.
(all via ecf)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
---------------..----------------------------..-----X
HANNAH BUCKSTINE,
Index No.: 57710/2016
Plaintiff,
-against-
TRIAL READINESS
STIPULATION & ORDER
JORDAN SCHOR, JORDAN'S OF NEW PALTZ LLC,
LCORE ENTREPRISE CORP., WAYNE BRADFORD, AND
ROBERT GERMINARA (Deceased),
Defendants.
---.------------------------------------------ -----X
LCORE ENTREPRISE CORP.
Third-Party Plaintiff,
-against-
WAYNE BRADFORD,
Third-Party Defendant.
---------------------------------------------X
IT IS HEREBY STIPULATED AND AGREED Itis hereby stipulated and agreed by and between
allparties to the within action as follows:
1. DISCOVERY IS COMPLETE: All disclosure previously ordered herein has been completed
or waived and the matter isready for trial;and
2. NOTE OF ISSUE: Plaintiff shall serve and filea Note of Issue and Certificate of Readiness
via NYSCEF within twenty (20) days of entry of thisTrial Readiness Stipulation and Order; and
3. NOTE OF ISSUE IF PARTY HAS OPTED OUT OF NYSCEF : Plaintiffshall also serve a
of the Note of Issue and Certificate of Readiness within twenty (20) days of entry of thisTrial
copy
1
Readiness Stipulation and Order upon any party who has opted out of NYSCEF, and shall fileproof of
service thereof via NYSCEF; and
4. SUMMARY JUDGMENT MOTIONS: Any motion for summary judgment by any party
must be served via NYSCEF within 45 days following the filing of the Note of Issue; opposition papers
must be served via NYSCEF within 30 days of service of motion papers; and reply papers, ifany, must be
served via NYSCEF within 10 days following service of any opposition papers.
5. SUMMARY JUDGMENT MOTIONS IF PARTY HAS OPTED OUT OF NYSCEF: Ifa
party has opted out of NYSCEF, a copy of any motion for summary judgment, opposition papers, reply
papers must be served upon that party by mail with the prescribed time periods and an affidavit of such
service shall be uploaded to NYSCEF. The contents and provisions of the foregoing proposed stipulation are
agreed to,and the
parties request that the Court order same.
Dated: Chappaqua, New York
May 23, 2019
LAW OFFICE OF TODD J.KROUNER, P.C.
Todd J. Kro , Esq.
Attorneys for intiff
93 North Greeley Avenue
Chappaqua, New York 10514
(914) 238-5800
Frank Malpigli, Esq.
Miranda Sambursky Stone Sklarin Verveniotis Llp
Attorneys for Defendants Jordan Schor, and
Jordan's Of New Paltz LLC
240 Mineola Boulevard
Mineola, New York 11501
(516) 741-7676
2
Kunberty Hunt Le sq.
McCabe & Mack
Attorneys for Defendant Lcore Enterprise Corp.
63 Washington Street
P.O. Box 509
Poughkeepsie, New York 12602
(845)486-6800
By:
Stephen D. Donohue, Esq.
Attorney for Defendant Wayne Bradford
365 Route 304, Suite 203
Bardonia, NY 10954
(845) 623-2345
SO ORDERED:
Hon. Joan B. Lefkowitz, J.S.C.
3
By:
Kimberly Hunt Lee. Esq.
McCabe & Mack U P
Attorneys for Defendant I.core Enterprise Corp.
63 Washington Street
P.O. Box 509
Poughkeepsie, New York 12602
(845)486-6800
By: .
,dtepheb Do lohue, Esq.
Attorney tibr efendant Way ne Bradford
365 Route 4. Suite 203
Bardonia, NY 10954
(845) 623-2345
SO ORDERED:
Hon. Joan B. Lefkowitz, J.S.C.
3
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LAW OFFICE OF TODD J. KROUNER, P.C. 93 NORTH GREELEY AVENUE CHAPPAQUA, NEW YORK 10514 (914)238-5800 TODD J. KROUNER* *ADMITTED IN NY AND NJ May 28, 2019 VIA ECF Hon. Joan. B. Letkowitz, JSC Attn: Jeannette Millner, Esq. Court Attorney Referee Westchester County Courthouse 111 Dr. Martin Luther King, Jr.,Boulevard, Courtroom: 800 White Plains, New York 10601 Re: Buckstine v. Schor. et al. Index No.: 57710/2016 Dear Judge Lefkowitz: I am the attorney for the plaintiff in the above-referenced action. Enclosed is a fully executed Trial Readiness Stipulation and Order ("Stipulation") for Your Honor's review and signature. Based on this Stipulation, counsel for the parties are not appearing at tomorrow's Trial Readiness Conference. Respectfully submitted, Todd J. er TJK/ag cc: Frank Malpigli, Esq. Kimberly Hunt Lee, Esq. Stephen Donohue, Esq. (all via ecf) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER ---------------..----------------------------..-----X HANNAH BUCKSTINE, Index No.: 57710/2016 Plaintiff, -against- TRIAL READINESS STIPULATION & ORDER JORDAN SCHOR, JORDAN'S OF NEW PALTZ LLC, LCORE ENTREPRISE CORP., WAYNE BRADFORD, AND ROBERT GERMINARA (Deceased), Defendants. ---.------------------------------------------ -----X LCORE ENTREPRISE CORP. Third-Party Plaintiff, -against- WAYNE BRADFORD, Third-Party Defendant. ---------------------------------------------X IT IS HEREBY STIPULATED AND AGREED Itis hereby stipulated and agreed by and between allparties to the within action as follows: 1. DISCOVERY IS COMPLETE: All disclosure previously ordered herein has been completed or waived and the matter isready for trial;and 2. NOTE OF ISSUE: Plaintiff shall serve and filea Note of Issue and Certificate of Readiness via NYSCEF within twenty (20) days of entry of thisTrial Readiness Stipulation and Order; and 3. NOTE OF ISSUE IF PARTY HAS OPTED OUT OF NYSCEF : Plaintiffshall also serve a of the Note of Issue and Certificate of Readiness within twenty (20) days of entry of thisTrial copy 1 Readiness Stipulation and Order upon any party who has opted out of NYSCEF, and shall fileproof of service thereof via NYSCEF; and 4. SUMMARY JUDGMENT MOTIONS: Any motion for summary judgment by any party must be served via NYSCEF within 45 days following the filing of the Note of Issue; opposition papers must be served via NYSCEF within 30 days of service of motion papers; and reply papers, ifany, must be served via NYSCEF within 10 days following service of any opposition papers. 5. SUMMARY JUDGMENT MOTIONS IF PARTY HAS OPTED OUT OF NYSCEF: Ifa party has opted out of NYSCEF, a copy of any motion for summary judgment, opposition papers, reply papers must be served upon that party by mail with the prescribed time periods and an affidavit of such service shall be uploaded to NYSCEF. The contents and provisions of the foregoing proposed stipulation are agreed to,and the parties request that the Court order same. Dated: Chappaqua, New York May 23, 2019 LAW OFFICE OF TODD J.KROUNER, P.C. Todd J. Kro , Esq. Attorneys for intiff 93 North Greeley Avenue Chappaqua, New York 10514 (914) 238-5800 Frank Malpigli, Esq. Miranda Sambursky Stone Sklarin Verveniotis Llp Attorneys for Defendants Jordan Schor, and Jordan's Of New Paltz LLC 240 Mineola Boulevard Mineola, New York 11501 (516) 741-7676 2 Kunberty Hunt Le sq. McCabe & Mack Attorneys for Defendant Lcore Enterprise Corp. 63 Washington Street P.O. Box 509 Poughkeepsie, New York 12602 (845)486-6800 By: Stephen D. Donohue, Esq. Attorney for Defendant Wayne Bradford 365 Route 304, Suite 203 Bardonia, NY 10954 (845) 623-2345 SO ORDERED: Hon. Joan B. Lefkowitz, J.S.C. 3 By: Kimberly Hunt Lee. Esq. McCabe & Mack U P Attorneys for Defendant I.core Enterprise Corp. 63 Washington Street P.O. Box 509 Poughkeepsie, New York 12602 (845)486-6800 By: . ,dtepheb Do lohue, Esq. Attorney tibr efendant Way ne Bradford 365 Route 4. Suite 203 Bardonia, NY 10954 (845) 623-2345 SO ORDERED: Hon. Joan B. Lefkowitz, J.S.C. 3